Panoramic Investment Advisors (“PIA” or “firm”) is an investment management firm located in Glendale, Colorado. Our firm became a registered investment adviser in November 2017; Steven Salter is the sole Managing Member, and Stacie Craddock is the Chief Compliance Officer of PIA. PIA specializes in investment advisory services for individuals, high net worth individuals, employee-sponsored retirement plans, institutions, charitable organizations, trusts, and estates. Our firm is committed to providing assistance that helps clients achieve their stated financial goals and build, manage, and preserve their wealth. PIA will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you, the client, and PIA execute a Discretionary Investment Management Agreement. INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES PIA manages advisory accounts on a discretionary basis. Our firm determines the client's objectives, time horizons, risk tolerance, and liquidity needs during personal discussions with clients. As appropriate, we will also review a client's prior investment history, family composition, and background. Based on the individual review, PIA will develop a client's profile and investment plan. The firm then creates and manages the client’s investments based on that investment plan. With our discretionary relationship, PIA will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. PIA trades these portfolios based on the combination of the firm’s market views and the client’s financial goals. PIA tailors our advisory services to meet our clients' needs and seeks to ensure that the client’s portfolio is managed in a manner consistent with those needs and objectives. The client will have the ability to leave standing instructions with the firm to refrain from investing in specific industries or invest in limited amounts of securities. The client must notify PIA immediately if circumstances have changed concerning their goals. PIA may accept accounts with particular restrictions if circumstances warrant. PIA primarily allocates client assets among various equities, exchange-traded funds ("ETFs"), mutual funds, and debt securities in accordance with their stated investment objectives. Once the firm has determined the types of investments to be included in the client’s portfolio and allocated them, the firm will provide on-going investment review and management services. This approach requires PIA to review your portfolio periodically. Account supervision is guided by the written profile and investment plan of the client. Where appropriate, PIA provides advice about any type of legacy (prior) position held in client portfolios. Typically, these are assets that are ineligible to be held at our primary custodian. Clients will engage our firm to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, and assets held in employer-sponsored retirement plans and qualified tuition plans (i.e., 529 plans). PIA has limited authority to direct the custodian to deduct our investment advisory fees from your accounts, but only with the client's appropriate written authorization. The client is advised and is expected to understand that our firm’s past performance is not a guarantee of future results. Specific market and economic risks exist that adversely affect an account's performance and could possibly result in capital losses in client accounts. PONTERA - PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY) We utilize the third-party platform, Pontera, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. MARCH 2024 | PAGE 4 We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. SMA SUB-ADVISOR (“SMA”) If deemed appropriate, our firm utilizes the services of a SMA for the management of your accounts. Investment advice and trading of securities will only be offered by or through the chosen SMA. Our firm will not offer advice on any specific securities or other investments in connection with this service. Prior to referring you, our firm will provide initial due diligence on SMA’s and ongoing reviews of their management of your accounts. To assist in the selection of a SMA, our firm will gather your information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will periodically review SMA reports provided to you. Our firm will contact you from time to time in order to review their financial situation and objectives; communicate information to SMA’s as warranted; and assist you in understanding and evaluating the services provided by the SMA. You will be expected to notify our firm of any changes in your financial situation, investment objectives, or account restrictions that could affect your financial standing. Our firm takes actions on behalf of you to hire or fire the SMA sub-advisor used in the implementation of your investment plan and execution of the Advisory Agreement with our firm. Therefore, the firm has the discretionary authority to hire or fire the manager or to allocate assets among managers without obtaining your consent. The services provided by the SMA include:
• Assessment of your investment needs and objectives.
• Implementation of an asset allocation.
• Delivery of suitable style allocations (e.g., Income, Large Cap, Small Cap, Growth, Value, etc.).
• Facilitation of portfolio transactions.
• Ongoing monitoring of investment vehicles performance.
• Review of your accounts for adherence to policy guidelines and asset allocation.
• Reporting of your portfolio activity. FINANCIAL PLANNING Through the financial planning process, our team at PIA strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With each family's unique goals and circumstances in mind, our team will offer financial planning ideas and strategies to address the client's holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client's other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure all parties' coordinated efforts toward their stated goals. Such services include various reports on specific goals and objectives or general investment or planning recommendations, guidance to outside assets, and periodic updates. MARCH 2024 | PAGE 5 Our firm’s specific services in preparing a client’s plan may include: § Review and clarification of the client’s financial goals § Assessment of the client’s overall financial position, including cash flow, balance sheet, investment strategy, risk management, and estate planning § Creation of a unique plan for each goal the client has, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals § Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal; including IRA and qualified plans, taxable, and trust accounts that require special attention § Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible

company benefits; and § Crafting and implementation of, in conjunction with the client’s estate or corporate attorneys as a tax advisor, an estate plan to provide for you and/or your heirs in the event of incapacity or death A written evaluation of each client's initial situation or financial plan is provided to the client. An annual review will be provided by the advisor if indicated by the client and advisor per the Agreement. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. RETIREMENT PLAN CONSULTING SERVICES Retirement Plan Consulting Services consists of acting as a service provider liaison, providing participant enrollment meetings, and assisting with participant education. SERVICE PROVIDER LIAISON PIA will act as a liaison between the Business Owner and service providers, product sponsors, and/or vendors. In such cases, the firm shall act only to assist communications between the Business Owner and service providers of the plan. PARTICIPANT ENROLLMENT PIA will assist a business owner in enrolling Plan participants in the plan, including conducting an agreed-upon number of enrollment meetings. As part of such meetings, the firm will provide participants with information about the plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the plan, and the operation of the plan. PLAN EDUCATION PIA will assist in plan participant education, including preparing educational materials and/or conducting investment education seminars and meetings for plan participants. Such meetings may be on a group and/or individual basis. Such meetings shall not include specific investment advice about investment options under the plan as appropriate for an individual participant but may include general education on the investment models. Plan participants have the ability to exercise control over the assets in their account, and we have no authority or discretion to direct the investment of assets of any participant’s account under the Retirement Plan Consulting services offered by our firm. MARCH 2024 | PAGE 6 DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. CONSULTING SERVICES PIA will also provide clients investment advice on a more limited basis on one or more areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, our firm provides advice on non-securities matters about the render of estate planning, insurance, real estate, and annuity advice, or any other business advisory/consulting services for equity or debt investments in privately-held businesses. In these cases, you, the client, will be required to select your investment manager, custodian, and/or insurance company for the implementation of consulting recommendations. If you, the client, have needs that include brokerage and/or other financial services, we, the firm, will recommend using one of several investment managers, brokers, banks, custodians, insurance companies, or other financial professionals ("firms"). The client must independently evaluate these firms before opening an account or transacting business and have the right to transact business through any firm you choose. The client has the right to choose whether to follow the consulting advice that we provide. MONEYGUIDE PRO, AND EMONEY ADVISOR PLATFORM PIA makes available “MoneyGuide Pro”, and the “eMoney Advisor Platform” to clients to provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by PIA (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not PIA, shall be MARCH 2024 | PAGE 7 exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed in writing, PIA’s service relative to the Excluded Assets is limited to reporting only. Therefore, PIA shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If PIA is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and PIA shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that PIA provide investment advisory services for the Excluded Assets, the client may engage PIA to do so pursuant the terms and conditions of an agreement between PIA and the client. MoneyGuide Pro and eMoney Advisor Platform also provides access to other types of information, including financial planning concepts, which should not be construed as personalized investment advice or recommendations provided by PIA. PIA shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney Advisor Platform without PIA’s assistance or oversight. OTHER BUSINESS NAMES Our firm offers services through our network of investment advisor representatives (“Advisor Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of our firm. The IARs are under our firm's supervision, and the advisory services of the IAR are provided through our firm. WRAP FEE PROGRAM PIA does not participate in a Wrap Fee Program. ASSETS As of December 31, 2023 our firm manages $242,035,085 in discretionary assets. PIA currently does not manage non-discretionary assets.